Portfolio Projector, LLC (“Portfolio Projector,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our services (collectively, the “Service”), and the choices and rights you have, including your choices about advertising and tracking technologies. The Service is intended for users located in the United States. This Policy is incorporated into our Terms & Conditions.
1. Consent
By creating an account, submitting information, or using the Service, you consent to our collection, use, processing, disclosure, and retention of your information as described here and as permitted by law. Where we rely on consent to process certain information (including sensitive information, where required), we obtain it separately and you may withdraw it as described in this Policy.
2. Children
The Service is not intended for, and we do not knowingly collect information from, anyone under eighteen (18) years of age. If we learn that we have collected information from a person under 18, we will delete it promptly.
3. Information We Collect
- Personal Data – information that identifies you, such as name, email, postal address, phone number, account credentials, payment information, and IP address, which you provide when you register, purchase, contact us, or use the Service.
- Usage Data – information about how you interact with the Service, such as pages viewed, access times, device and browser type, and operating system, collected automatically through cookies and similar technologies.
- Identifiers and Advertising Data – online identifiers such as cookie IDs, device and advertising identifiers, pixel and SDK identifiers, and IP-derived approximate location, collected through the analytics and advertising technologies described in Section 8. We configure these technologies not to receive your Financial and Investment Data or account credentials.
- Financial and Investment Data (sensitive) – if you connect accounts or enter information manually, we collect data such as bank and transaction data (via Plaid), brokerage and investment-account data, property details, purchase prices, valuations, income and expenses, net-worth estimates, cash-flow projections, and portfolio performance. We treat this as sensitive personal information and use it solely to provide and improve the Service and as described here. We do not use it for advertising.
- Inferred and Derived Data – insights and scores we derive from your data, such as portfolio risk scores and financial-independence projections, generated by our automated and AI-powered features.
4. Sources of Information
We collect information directly from you; automatically through your use of the Service and the technologies in Section 8; and from third parties, including Plaid (financial-account data), Stripe (payment and fraud-prevention data), Clerk (authentication data), and property- and market-data providers.
5. How We Use Information
We use Personal, Usage, Identifier, Financial, and Derived Data to: provide, maintain, and improve the Service; verify identity and authenticate accounts; process payments; communicate about your account, support, and (where permitted) updates and promotions; measure and analyze site and product usage and the performance of our marketing; deliver and measure advertising, including cross-context behavioral advertising through the partners described in Section 8; conduct analytics and research; detect and prevent fraud and misuse; comply with legal obligations and enforce our Terms; and for other purposes with your consent. We do not use sensitive personal information, including Financial and Investment Data, for advertising.
Basis for processing. We process your information to perform our contract with you, to pursue our legitimate business interests (such as securing, operating, analyzing, and improving the Service and our marketing), to comply with legal obligations, and with your consent where we rely on it. We do not use sensitive personal information, including Financial and Investment Data, for advertising.
6. AI/ML Model Development
We may use anonymized and aggregated data derived from user interactions to train, improve, and develop our artificial-intelligence and machine-learning models and features. We do not use individually identifiable Personal Data or individually identifiable Financial Data to train these models without your separate express consent. You may opt out of having your anonymized data used for model development by contacting legal@portfolioprojector.com. We may use and disclose aggregated or de-identified data, which cannot reasonably identify you, for any lawful purpose.
7. Automated Decision-Making and Profiling
Some features use automated processing and profiling to generate scores and projections (for example, portfolio risk scores and financial-independence estimates). These outputs are informational estimates only, do not constitute advice, and are not used to make legal or similarly significant decisions about you without human involvement. Where required by law, you may request information about this processing, opt out, or appeal as described in Sections 17–19. We label automated, model-generated outputs within the Service.
8. Cookies, Analytics, Advertising & Tracking Technologies
We and our providers use cookies, pixels, tags, SDKs, and similar technologies on our marketing website and in the app to operate the Service, remember preferences, secure your account, analyze usage, and deliver and measure advertising — including cross-context behavioral (targeted) advertising. The table below summarizes the main technologies we use. Some of these technologies disclose information to third parties in ways that certain state privacy laws treat as a “sale” or “sharing” of personal information; see Sections 11 and 12 for the categories shared and your opt-out choices.
- Google Analytics 4 (Analytics) – processes usage data, device/browser info, pages viewed, cookie/online identifiers, and truncated IP. Recipient: Google, as our service provider/processor.
- Google Signals + Google Ads (Advertising — cross-context / targeted) – processes cross-device activity, demographics, and remarketing-audience membership. Recipient: Google, as a third party for cross-context behavioral advertising.
- Meta Pixel (Advertising — remarketing) – processes page views and events, cookie identifiers, and IP. Recipient: Meta, as a third party for cross-context behavioral advertising.
- Meta Conversions API (Advertising — server-side measurement) – processes conversion events and hashed identifiers sent server-side. Recipient: Meta, as a third party.
- PostHog (Product analytics) – processes product events, usage, device, and identifiers. Recipient: PostHog, as our service provider/processor.
- Sentry (Error monitoring & security) – processes error/performance metadata, device, and IP-derived approximate location. Recipient: Sentry, as our service provider/processor.
- Stripe (Payments & fraud prevention — essential) – processes checkout/session and fraud-signal data. Recipient: Stripe, as our service provider/processor.
- Clerk (Authentication & account security — essential) – processes login, session, and device data. Recipient: Clerk, as our service provider/processor.
8.1 How these run; no cookie banner or CMP
Essential technologies (such as authentication and payment/fraud tools) are necessary to operate the Service and secure your account and cannot be disabled without affecting functionality. Analytics technologies (such as Google Analytics 4 and PostHog) run by default and are suppressed when you opt out, including through a Global Privacy Control signal. Advertising technologies (such as Google Signals / Google Ads and the Meta Pixel / Conversions API) are used for cross-context behavioral advertising and are suppressed for users who opt out. We are a US-only product and do not use a cookie banner or a third-party consent-management platform; instead, we honor opt-out preference signals and offer the controls described in Section 12, and you can also manage cookies through your browser settings.
8.2 Opt-out preference signals (Global Privacy Control) — our primary web opt-out
We recognize the Global Privacy Control (GPC) and similar browser-based opt-out preference signals, and honoring GPC is our primary opt-out method on our website. When we detect such a signal, we treat it as a valid request to opt the associated browser or device out of the “sale” or “sharing” of personal information and targeted advertising, as required by the California Consumer Privacy Act and other applicable state laws; and we store that preference for your browser or account. Because these signals are device- and browser-specific, they may not be associated with your account unless you are logged in, and they do not apply within the mobile app; use the in-app control described in Section 12 for the app.
8.3 Server-side tracking
Some measurement occurs server-to-server (for example, the Meta Conversions API and server-side analytics events). Your opt-out choices in Section 12 apply to server-side sharing as well; when you opt out, we do not transmit advertising conversion data associated with you to advertising partners for cross-context behavioral advertising.
9. Payment and Authentication Providers (Stripe and Clerk)
We use Stripe, Inc. to process payments. When you pay, your payment information (including name, billing address, and card details) is transmitted directly to Stripe, which acts as our processor and uses the information to process payments, verify identity, prevent fraud, and meet legal obligations. We do not store your full card number; we may retain limited details (such as the last four digits and expiration date) for records and support. Stripe’s use of your data is governed by the Stripe Privacy Policy at stripe.com/privacy.
We use Clerk, Inc. (“Clerk”) to provide account registration, login, and authentication. Clerk processes your account and credential data and related security signals on our behalf as a service provider to authenticate you and protect your account. We do not use Clerk data for advertising.
10. Financial Data Integration (Plaid)
If you connect financial accounts, your account credentials and account data are accessed and processed by Plaid, Inc. on our behalf to enable account-integration features. Your credentials are transmitted directly to and handled exclusively by Plaid and are not stored by us. Plaid’s collection and use of your information is governed by Plaid’s End User Privacy Policy at plaid.com/legal. You may revoke Plaid’s access at any time through your account settings or at my.plaid.com. We do not disclose financial-account data to advertising partners.
11. How We Share Information
We disclose personal information to the categories of recipients below. Some of these disclosures — specifically, disclosures to advertising partners through the technologies in Section 8 — are considered a “sale” or “sharing” of personal information for cross-context behavioral (targeted) advertising under the CCPA and similar state laws. You can opt out as described in Section 12.
Advertising and analytics partners. We use third-party analytics and advertising technologies (including Google Analytics 4 with Google Signals, Google Ads, the Meta Pixel, and the Meta Conversions API) that disclose online identifiers, device information, internet and other electronic network activity, and inferences to Google and Meta. When used with advertising features (such as Google Signals / Google Ads remarketing and Meta remarketing), these disclosures support cross-context behavioral advertising and are treated as a “sale” and/or “sharing” of personal information under applicable law. We do not disclose your Financial and Investment Data, account credentials, or other sensitive personal information to advertising partners.
Service providers and sub-processors. We share information with vendors that process it on our behalf under contract and only for our business purposes, including hosting, payment processing (Stripe), authentication (Clerk), financial-account aggregation (Plaid), product analytics (PostHog), error monitoring and security (Sentry), identity verification, and customer support. We maintain and will provide, on request, a current list of key sub-processors.
Affiliates. Subsidiaries or affiliated companies under common control that adhere to this Policy.
Business transfers. Acquirers or successors in a merger, acquisition, financing, or sale, with notice via email and a prominent posting at least thirty (30) days before your data becomes subject to a materially different policy.
Legal and safety. Authorities or others when required by law or legal process, or to protect our rights, property, safety, or that of others.
With your consent. Other parties with your consent or at your direction.
12. Your Privacy Choices — Opt Out of Sale/Sharing and Targeted Advertising
We are a US-only product and do not use a cookie banner or a consent-management platform. You can opt out of the “sale” or “sharing” of your personal information and of targeted / cross-context behavioral advertising in any of these ways:
- Global Privacy Control (GPC) — website. Enable GPC in your browser or a browser extension. We honor it as our primary opt-out for the website and store the preference (see Section 8.2).
- In-app control — mobile app. Use the privacy/opt-out control in the app’s settings, together with your device-level ad settings, to opt out of advertising-related tracking in the app.
- By request — any user. Email legal@portfolioprojector.com with “Opt-Out Request” in the subject line, and we will opt you out of the sale/sharing of your personal information and of targeted advertising.
- Directly with the platforms. You may also adjust Google ad settings at adssettings.google.com and Meta ad preferences within your Meta account.
When you opt out, we suppress advertising technologies for you and apply your choice to our advertising partners — including for server-side events (such as the Meta Conversions API) and Google advertising features, not only the client-side pixel — for example by enabling Meta “Limited Data Use” and Google “Restricted Data Processing” (or equivalent), so that your information is not used for cross-context behavioral advertising. Analytics may continue to operate unless you opt out via GPC. We do not use sensitive personal information, including Financial and Investment Data, for targeted advertising, and we will not discriminate against you for exercising these choices.
13. Promotions and Free Trials
From time to time we may offer promotions or free trials, limited to eligible first-time subscribers and not combinable with other offers. Unless stated otherwise, a trial automatically converts to a paid plan at the end of the trial period unless you cancel; where required by law, we will send a reminder before it ends. You may cancel at any time in your account settings.
14. Data Retention
We retain information for as long as needed for the purposes described here and to meet legal, tax, accounting, and record-keeping requirements, after which we securely delete or irreversibly de-identify it:
- Account information: for the life of your account plus three (3) years after closure.
- Financial and portfolio data: for the life of your account plus seven (7) years to meet tax and financial record-keeping requirements.
- Payment records: seven (7) years to comply with financial regulations.
- Usage, analytics, and advertising identifiers: twenty-four (24) months.
- Marketing data: until you opt out or request deletion.
Where you exercise a right to delete, we will honor it subject to these retention requirements and other legal exceptions, and will explain any basis for retaining information we cannot delete.
15. Security
We maintain a written information-security program with administrative, technical, and physical safeguards appropriate to the sensitivity of the data, including encryption of data in transit (TLS/SSL) and at rest, access controls and authentication, network and application protections, vendor oversight, and regular risk assessments and testing. We designate personnel responsible for our information-security program, who can be reached at legal@portfolioprojector.com. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for safeguarding your account credentials.
16. Data Breach Notification
If a security incident involving unauthorized access to, disclosure of, or loss of your personal information occurs, we will: notify you by email to the address on file without undue delay; notify regulators and other authorities within the time required by applicable law; and provide a description of the incident, the categories of information affected, the steps we are taking, and recommended steps you can take. We will provide notice within the timeframe required by applicable law and in any event without unreasonable delay.
17. Your Privacy Rights and Choices
Depending on your jurisdiction, you may have rights to access, correct, delete, port, or restrict processing of your personal data, and to opt out of certain processing (including targeted advertising and the sale/sharing of personal information as described in Section 12). To exercise these rights, email legal@portfolioprojector.com with “Privacy Rights Request” in the subject line, including your name and the email associated with your account and describing your request. We will verify your identity before responding. We will respond within the time required by law (generally within forty-five (45) days, extendable by an additional forty-five (45) days for complex requests, with notice). You may opt out of marketing emails using the unsubscribe link in any marketing message. We will not discriminate against you for exercising your rights.
18. California Privacy Rights (CCPA/CPRA)
If you are a California resident, you have the rights to know, access, delete, and correct your personal information; to opt out of the sale or sharing of personal information; to limit the use of sensitive personal information (including financial data) to what is necessary to provide the Service; and to non-discrimination. As described in Sections 8, 11, and 12, we use advertising technologies (Google Signals / Google Ads and the Meta Pixel / Conversions API) that constitute a “sale” and/or “sharing” of certain identifiers, internet-activity information, and inferences for cross-context behavioral advertising. You may exercise your right to opt out by sending a Global Privacy Control signal (our primary method for the website, which we honor), by using the in-app control, or by emailing us with an opt-out request; see Section 12. We do not sell or share sensitive personal information or the personal information of consumers we know to be under 16. Submit requests at legal@portfolioprojector.com or by mail to Portfolio Projector, LLC, PO Box 93, Farmington, MI 48332, and we will respond within forty-five (45) days of a verifiable request.
Categories collected and shared. In the past 12 months we have collected these CCPA categories: identifiers; California Customer Records categories; commercial information; internet/network activity; geolocation (approximate); financial information; and inferences. We “sell”/“share” (for cross-context behavioral advertising) identifiers, internet/network activity, and inferences with advertising partners (Google, Meta). We do not sell or share financial information or other sensitive personal information.
19. Other U.S. State Privacy Rights
If you reside in a state with a comprehensive consumer-privacy law (including, for example, Virginia, Colorado, Connecticut, Texas, Utah, Oregon, and others), you may have rights to confirm whether we process your personal data; to access, correct, delete, and obtain a portable copy of it; and to opt out of targeted advertising, the sale of personal data, and certain profiling. We honor recognized universal opt-out mechanisms, including Global Privacy Control, for targeted advertising and sale/sharing. Where required, we obtain your consent before processing sensitive data, including financial information.
How to exercise and appeal. To exercise these rights, send a Global Privacy Control signal (website), use the in-app control (app), or contact legal@portfolioprojector.com. If we decline your request, you may appeal by replying to our decision or emailing legal@portfolioprojector.com with “Privacy Appeal” in the subject line. If we deny your appeal, you may contact your state Attorney General.
20. Financial Privacy Notice (GLBA)
To the extent Portfolio Projector is a “financial institution” under the Gramm-Leach-Bliley Act (GLBA), this Section serves as our financial privacy notice. We collect nonpublic personal information as described in Section 3; we use and share it only as described in this Policy and as permitted by the GLBA and its implementing rules; and we maintain safeguards designed to protect it as described in Section 15. We do not disclose nonpublic personal information about you to nonaffiliated third parties except as permitted by law or as described in this Policy, and we do not disclose it to advertising partners.
21. U.S.-Only Service
The Service is intended for and directed to users located in the United States. It is not directed to individuals in the European Economic Area, the United Kingdom, Switzerland, or other regions, and we do not knowingly offer it to them. If you access the Service from outside the United States, you do so on your own initiative and are responsible for compliance with local laws, and you understand that your information will be processed in the United States as described in Section 22. If we later make the Service available to users in the EEA or UK, we will update this Policy to add the required protections (including legal bases for processing, data-subject rights, an EU/UK representative, and appropriate cross-border transfer mechanisms) before doing so.
22. International Data Transfers
Portfolio Projector is located in and operates the Service from the United States, and information is stored and processed in the United States. If you access the Service from outside the United States, your information will be transferred to and processed in the United States, where data-protection laws may differ from those in your location, and you consent to such processing where permitted by law.
23. Biometric Information
We do not currently collect biometric information. If we introduce features that do, we will provide clear notice, obtain your explicit consent before collection, use the data only for the disclosed purpose, retain it only as long as needed, and update this Policy accordingly.
24. Third-Party Sites
The Service may link to third-party websites we do not control. We are not responsible for their privacy practices, and we encourage you to review their policies. This Policy applies only to the Service.
25. Changes to This Policy
We may update this Policy from time to time and will post changes with an updated “Last updated” date. For changes that materially affect how we collect, use, or share your data, we will provide advance notice by email to the address on file before they take effect. Your continued use of the Service after the effective date constitutes acceptance.
26. Contact Us
For questions, complaints, or requests regarding this Policy or our data practices, contact our Privacy Team:
Portfolio Projector, LLC
Attn: Legal Department
PO Box 93
Farmington, MI 48332
Email: legal@portfolioprojector.com
Phone: (877) 369-4517